Hayes v. State
94 So. 3d 452
| Fla. | 2012Background
- Hayes challenged denial of a peremptory strike to juror Haupt during jury selection.
- Trial court treated the challenge as for-cause, not peremptory, and did not conduct Melbourne’s step-three genuineness inquiry.
- First District affirmed, relying on trial court credibility and deferring to steps one–two, despite State concession of error.
- State conceded the trial court erred by not applying Melbourne’s three-step process and ordering remand for a new trial.
- Record shows defendant’s strike reason (relatives in law enforcement) was facially neutral; no demonstrated pretext or discriminatory intent.
- Court grants certiorari to quash First District and remand for new trial with proper Melbourne analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court properly apply Melbourne’s step-three genuineness inquiry? | Hayes argues the trial court failed Melbourne step-three. | State contends the district properly reviewed the record. | No; Melbourne step-three not conducted; remand required. |
| Was the State required to prove discriminatory purpose after a facially neutral reason? | Presumption of nondiscrimination shifts burden to opponent. | Opponent must show pretext; here record lacks pretext. | Burden not properly applied; remand necessary to permit genuineness inquiry. |
| Does deference to trial-court credibility undermine Melbourne’s corrective procedure? | Deference prevented meaningful appellate review of genuineness. | Trial court credibility should be given weight. | Yes; misapplication warrants reversal and remand for new trial. |
| Is remand for a new trial the appropriate remedy for Melbourne misapplication? | Remand ensures proper Melbourne analysis before verdict. | Remand aligns with correcting error. | Remand for new trial appropriate. |
Key Cases Cited
- Melbourne v. State, 679 So.2d 759 (Fla.1996) (three-step Melbourne procedure for discriminatory peremptory challenges)
- J.E.B. v. Alabama ex rel. T.B., 511 U.S. 127 (U.S.1994) (peremptory challenges and impartial jury rights)
- Busby v. State, 894 So.2d 88 (Fla.2004) (role and limits of peremptory challenges; avoid discrimination)
- Welch v. State, 992 So.2d 206 (Fla.2008) (Melbourne applicability to gender-based discrimination)
- Murray v. State, 3 So.3d 1108 (Fla.2009) (genuineness inquiry guidance under Melbourne)